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Articles by Will Bonner
The Bank of England’s Updated Assessment of Optimal Bank Capital
How much bank capital best serves the public interest? The answer depends on where the net social value of bank capital is maximized. The benefits of capital include a reduced likelihood of bank failure and broader financial crises while the costs include more expensive credit, leading to slower GDP growth.
Liquidity Regulations, Prepositioned Discount Window Collateral and the Central Bank Balance Sheet
Remarks presented at the European Central Bank, Frankfurt, Germany, May 20, 2026; the Bank for International Settlements, Basel, Switzerland, May 21, 2026; and the Sveriges Riksbank, Stockholm, Sweden, May 25, 2026[1] Two recent announcements by senior U.S. officials carry significant consequences for the Federal Reserve.
BPI Comments on Federal Reserve FR Y-11 and FR 2314 Reporting Requirements
To Whom It May Concern: The Bank Policy Institute[1] appreciates the opportunity to provide comments to the Board of Governors of the Federal Reserve System regarding the reporting of the financial statements of certain subsidiaries of U.S. organizations on the FR Y-11 and the FR 2314.
4 Takeaways from John Court’s Testimony on Modernizing the Bank Secrecy Act
BPI Executive Vice President, General Counsel and Chief Operating Officer John Court testified today before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions at a hearing titled “Modernizing the BSA for Financial Crime in the 21st Century.” Court discussed the importance of modernizing the Bank Secrecy Act and emphasized the need to transition to a more effective, risk-based system that leverages technological innovation...
BPI’s John Court Testifies on BSA Modernization
Washington, D.C. — John Court, Bank Policy Institute Executive Vice President, General Counsel and Chief Operating Officer, will testify today before the U.S. House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions at a hearing on “Modernizing the BSA for Financial Crime in the 21st Century.” In his testimony, Court identifies reforms that would bolster the U.S. anti-money laundering regime and shift its focus away from technical...
Banking Trades Statement on Senate Banking Committee Vote to Advance Clarity Act
Washington, D.C. — Following today’s Senate Banking Committee vote to advance the Digital Asset Market Clarity Act, the American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Financial Services Forum, Independent Community Bankers of America and National Bankers Association issued the following joint statement: “Today’s Senate Banking Committee vote on the Clarity Act marks an important step in establishing a regulatory framework around digital assets, a goal the...
BPInsights: May 9, 2026
Sens. Thom Tillis (R-NC) and Angela Alsobrooks (D-MD) last week released legislative language on stablecoin issuers’ ability to pay yield, a key part of the pending crypto market structure bill.
Banking Trade Groups Urge Senate Banking Leaders to Strengthen Stablecoin Yield Guardrails to Prevent Deposit Flight
Washington, D.C. — A coalition of financial trade associations representing banks of all sizes today urged Senate Banking Committee leaders to make important technical refinements to proposed payment stablecoin yield language in the CLARITY Act, warning that allowing interest‑like yield on stablecoins could weaken bank deposits and reduce credit available to consumers, small businesses and farmers.
Research Exchange: April 2026
After the Global Financial Crisis, new home construction remained historically low even as the housing market recovered. This paper demonstrates a link between this slowdown and post-GFC regulatory reforms, including Dodd-Frank Act stress tests, which treated construction loans as among the riskiest bank assets.
Banking Trades Statement on Crypto Market Structure Yield Language
Washington, D.C. – Following the release of proposed language on stablecoin yield in the Clarity Act, the American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Financial Services Forum and Independent Community Bankers of America issued the following joint statement: “We appreciate the work by Senator Tillis and Senator Alsobrooks to address the concerns from banks of all sizes around the risk of deposit flight from paying yield on stablecoins.
BPInsights: May 2, 2026
BPI President and CEO Greg Baer testified Tuesday at a House Financial Services hearing titled “Prioritizing Main Street: Evaluating the Impact of Capital Proposals on Economic Growth and American Communities.” Baer discussed the U.S. banking agencies’ recent capital proposals, the interactions between different elements of the capital framework and the effects on the economy and the financial system.
5 Takeaways from Greg Baer’s Testimony on the Basel Capital Proposal
BPI President and CEO Greg Baer testified today at a House Financial Services hearing titled “Prioritizing Main Street: Evaluating the Impact of Capital Proposals on Economic Growth and American Communities.” Baer discussed the U.S. banking agencies’ recent capital proposals, the interactions between different elements of the capital framework and the effects on the economy and the financial system. Rep. Bill Huizenga (R-MI): Mr. Baer, I want to ask you.
BPI’s Greg Baer Testifies at Basel Hearing
Washington, D.C. — BPI President and CEO Greg Baer will testify today at a House Financial Services hearing titled “Prioritizing Main Street: Evaluating the Impact of Capital Proposals on Economic Growth and American Communities.” Baer will discuss the U.S. banking agencies’ recent capital proposals, the interactions between different elements of the capital framework and the effects on the economy and the financial system.
BPInsights: April 25, 2026
The U.S. financial system exists in two parallel tracks. On one side, banks are investing countless resources to protect the financial system from illicit activity — flagging suspicious transactions, executing stringent due diligence and working closely with law enforcement and national security agencies.
Time for a Reckoning on AML and Crypto
For decades, our government has counted primarily on the nation’s banks to identify suspicious activity and assist law enforcement and national security agencies in fighting criminals and terrorists. Executing that responsibility requires tens of thousands of bank employees and countless man-hours. But cryptocurrencies and stablecoins are increasingly becoming the coin of the realm for money launderers and terrorist financers.
Crypto Hacks and DeFi Runs
On April 18, 2026, crypto hackers stole an estimated $290 million from major decentralized finance (DeFi) lending platforms, exposing some lenders to potential losses. In addition, the largest DeFi lending platform, Aave, experienced mass withdrawals to the point where some crypto lenders, including stablecoin lenders, were unable to withdraw their funds. The hack not only exposed lenders to significant potential losses – it also highlights three inherent risks of DeFi lending.
Climate Transition Risk Cuts Both Ways
Since the adoption of the 2015 Paris Accord, global bank regulators and supervisors have focused on management of climate transition risk. Transition risk is the possibility that changes in government policies, legal decisions, technology or market demand may make fossil fuel or renewable energy technologies either more or less valuable. Bank regulators have almost exclusively presented transition risk as one-sided: green investments reduce transition risk.
Proposed OCC Changes Would Help Fix a Broken Supervisory Appeals System
Washington, D.C. – The OCC’s proposed changes to its framework for banks’ appeals of supervisory decisions would restore confidence, bolster accountability and improve transparency in the appeals process, the Bank Policy Institute, Independent Community Bankers of America and American Association of Bank Directors said in a comment letter filed yesterday.
BPInsights: April 18, 2026
Iran has demanded that ships pay tolls for accessing the Strait of Hormuz in cryptocurrency, according to the Financial Times recently. The waterway has become a flashpoint in the U.S. conflict with the Middle Eastern nation, with the U.S. military this week instituting a blockade of Iranian ports. The U.S. also issued new sanctions this week against individuals and companies connected with an Iranian smuggling network.
The Fed’s New Global Market Shock Methodology: Consistent, Coherent, But Containing One Fatal (But Correctible) Flaw
For the first time in the 15-year history of the Federal Reserve’s annual stress test capital adequacy exercise, the Fed released extensive documentation[1] of the models used to construct the Global Market Shock (GMS) component of the 2025 stress test and sought public comment. The GMS must be run by banks that have significant trading activity[2] if they are subject to the supervisory stress tests under Dodd Frank.
BPI Comments on California Corporate Greenhouse Gas Reporting Program
The Bank Policy Institute[1] appreciates the opportunity to provide further feedback to the California Air Resources Board regarding its implementation of California Senate Bill 253 (2023) and Senate Bill 261 (2023), each as amended by Senate Bill 219 (2024), in response to CARB’s solicitation of public comments on its March 23, 2026 public workshop, during which CARB requested feedback on its proposed regulatory concepts for subsequent regulation implementing SB 253 reporting requirements...
BPI Statement on the FCC’s Proposed “Know Your Customer” Rule
Washington, D.C. – BPI Senior Vice President and Associate General Counsel Drew Ruben issued the following statement today in response to the FCC’s proposed “Know Your Customer“ rule: “BPI strongly supports the FCC proposal to prevent criminals from exploiting telecom accounts and defrauding American consumers.
BPI Statement on Proposed Bank Secrecy Act Modernization Rule
Washington, D.C. – BPI Senior Vice President Clara Kim issued the following statement today in response to Treasury’s proposed updates to Bank Secrecy Act rules: “BPI appreciates Secretary Bessent’s leadership in reforming BSA rules to allow banks to refocus resources toward stopping illicit finance and away from check the box exercises, and we commend efforts to build up FinCEN’s role in AML/CFT supervision to help safeguard the financial system.
Open Banker: Fintechs with Fed Accounts Will Harm Consumers, Not Help Competition
Originally published by Open Banker America has one of the most competitive banking systems in the world, home to more than 4,000 banks, 4,000 credit unions, and over 10,000 fintech companies. These entities underlie the safe, efficient payment system in the U.S. that allows consumers significant choice in how they pay. But you wouldn’t know it by listening to fintech lobbyists.
Research Exchange: March 2026
A 2018 Supreme Court decision invalidating a federal law banning sports betting in the U.S. has led to its legalization in 38 states. This has resulted in a proliferation of sports betting activity, primarily in the form of “sportsbook” wagers using mobile or online applications. This paper examines the effects of legalization on betting behavior and consumer financial outcomes.
What They Are Saying About Fraud and Scams
Fraud and scams are surging across the United States, costing Americans billions of dollars each year. Banks invest heavily in fraud prevention and detection, but scams increasingly originate on social media platforms and through telecom networks — outside the banking system. From Capitol Hill to consumer advocates, there is a growing consensus that the platforms enabling these crimes must be held accountable. Here is what they are saying.
BPInsights: March 28, 2026
On Thursday, Federal Reserve Board Governor Stephen Miran gave a speech at the Economics Club of Miami on “Prospects for Shrinking the Fed’s Balance Sheet.” The Federal Reserve’s balance sheet is currently 84 percent of nominal GDP; before the Global Financial Crisis it was 24 percent. Miran indicated that the Fed’s balance sheet could be reduced gradually by $1 to $2 trillion without disrupting financial markets. Miran gave four reasons why the Fed should shrink its balance sheet.
BPI Hires Sam Fabens to Lead Communications Team
Washington, D.C. – The Bank Policy Institute today announced the hiring of Sam Fabens as Head of Communications. Sam will start the position on April 20. “We are excited to welcome Sam to BPI,” said Chief Public Affairs Officer Kate Childress.
BPInsights: March 21, 2026
The federal banking agencies on Thursday unveiled a revamped proposal on Basel III Endgame capital requirements. The package, revised from the 2023 iteration, aims to make requirements more risk-sensitive and account for the cumulative effect of the overall capital framework, including overlaps in capital requirements and stress testing. Comments on the proposal are due in 90 days.
Banking Trades Respond to Basel Proposal
Washington, D.C. — Following the release of the Basel proposal, the Bank Policy Institute, American Bankers Association, Consumer Bankers Association, Financial Services Forum and National Bankers Association issued a joint statement: Modernizing the U.S. bank capital framework supports consumers, job creators and communities across the country. Today’s proposal marks an important step forward.
The Evolving Competition from Nonbanks in Retail Banking Markets from the Perspective of the Survey of Consumer Finances
To what extent have depository institutions been losing ground to fintech companies and other nonbank financial service providers in the markets for consumer banking products and services over the past decade? How might this evolving competitive landscape be affecting consumer financial well-being?
The Evolving Competition from Nonbanks in Retail Banking Markets: Evidence from the Survey of Consumer Finances
Bank merger analysis traditionally has focused on competition among commercial banks and, to a lesser degree, other depository institutions, relying largely on deposit-based measures of market shares and concentration. There is widening recognition, however, that these measures likely understate banking market competitiveness, due to the expanding role of nonbank financial service providers, and of fintech companies in particular.
BPI’s Clara Kim Testifies Before House Committee
Washington, D.C. — Clara Kim, BPI Senior Vice President, will testify today before the U.S. House Financial Services Committee at a hearing titled “Updating America’s Financial Privacy Framework for the 21st Century.” Taking Stock of the Banking Privacy Landscape.
BPInsights: March 14, 2026
Federal Reserve Vice Chair for Supervision Michelle Bowman previewed the forthcoming Basel capital proposal in a speech and Q&A on Thursday at the Cato Institute. The proposal will build on the 2017 Basel agreement “while incorporating targeted adjustments to reflect U.S.-specific aspects of banking and financial markets,” Bowman said.
Banking Trades Respond to Vice Chair Bowman’s Basel Comments
Washington, D.C. — Following Vice Chair Bowman’s comments regarding what is next for the Basel proposal, the Bank Policy Institute, American Bankers Association and the Financial Services Forum issued a joint statement: Vice Chair Bowman’s recent remarks reflect a thoughtful, bottom-up approach towards addressing the concerns reflected in the 97 percent of commenters who identified issues with the previous Basel proposal.
Post-Crisis Government Litigation Led to a Decline in Low-Income Mortgage Lending
Beginning in 2011, the U.S. Department of Justice (DOJ) filed a series of lawsuits against mortgage lenders alleging fraud in the origination of loans insured by the Federal Housing Administration (FHA). The DOJ asserted that these practices caused the FHA to pay hundreds of millions of dollars in ineligible insurance claims and contributed to the depletion of its insurance fund. Ultimately, 31 large mortgage lenders paid over $5 billion to the federal government to settle these claims.
Bank Trades Comment on NIST’s Security Considerations for AI Agent Systems
Ladies and Gentlemen: BITS, the technology policy division of the Bank Policy Institute (“BPI/BITS”), together with the American Bankers Association (“ABA”), submit these comments in response to CAISI’s Request for Information regarding security considerations for AI agent systems.
BPI, Columbia Co-Host 10th Annual Conference on Bank Regulation
The 10th Annual Conference on Bank Regulation, co-hosted by the Bank Policy Institute and Columbia University School of International and Public Affairs, took place on Feb. 20, 2026. Each year, the conference brings together academics, regulators, and practitioners to discuss the latest research on banking and bank regulation. The overarching themes of this year’s conference were (1) innovation and automation in banking, (2) banking supervision and (3) digitalization and banking.
BPInsights: March 7, 2026
Crypto firm Kraken, a Wyoming Special Purpose Depository Institution, received approval from the Federal Reserve Bank of Kansas City for a “limited purpose” master account, according to announcements on Wednesday. Context. Master accounts are the endgame for crypto and fintech firms seeking direct access to Fed payment rails, and the Federal Reserve’s approval of Kraken’s request signals a pivotal expansion of such access for novel institutions.
BPI Responds to Executive Order on Fraud
Washington, D.C. – BPI issued a statement today in response to an Executive Order cracking down on fraud and scams: “We appreciate the Administration’s focus on fraud and impersonation scams, which are a pervasive problem affecting Americans. Many of these scams reach Americans through social media, digital advertising and telecom companies.
Joint Trades Statement on FAQs on the Capital Treatment of Tokenized Securities
Washington, D.C.—Following today’s joint issuance by the federal bank regulatory agencies of answers to frequently asked questions to clarify the capital treatment of tokenized securities, the Bank Policy Institute, Futures Industry Association, Global Blockchain Business Council, Global Digital Finance, Global Financial Markets Association, Institute of International Finance, International Swaps and Derivatives Association, and Securities Industry and Financial Markets Association issued the...
BPI Statement for the Record for House Financial Services Hearing on Fighting Fraud
The Bank Policy Institute (BPI) appreciates the opportunity to provide input to the Subcommittee on the hearing “Fighting Fraud on the Front Lines: Challenges and Opportunities for Financial Institutions.”[1] BPI member institutions are deeply committed to protecting customers and the integrity of the U.S. financial system from fraud and scams.
BPI Statement on Kraken Master Account
Washington, D.C. — BPI Co-Head of Regulatory Affairs Paige Pidano Paridon issued the following statement today in response to the Federal Reserve Bank of Kansas City’s approval of a master account request for Kraken: We are deeply concerned that the Federal Reserve Bank of Kansas City has approved an account request for a “limited purpose” master account—which appears to be a “skinny” account—before the Federal Reserve Board has finalized its policy framework for those accounts.
BPI Supports Main Street Capital Access Act
Dear Chairman Hill, Ranking Member Waters and Members of the Committee: The Bank Policy Institute (BPI) is writing in support of the Main Street Capital Access Act, which incorporates a series of critical reforms to rationalize the banking system’s regulatory framework and promote responsible and expanded access to credit across the U.S. economy.
BPI Statement on Reassessing and Reforming Bank Liquidity Requirements
Washington, D.C. — Today, Governor Bowman and Treasury Secretary Bessent (in prepared remarks) began the important process of reassessing and reforming bank liquidity requirements to ensure that they not only safeguard our nation’s banks but also allow those banks to make more loans to businesses and households. Proper calibration of liquidity regulations will allow banks to deploy their excess liquidity to better support economic growth rather than government growth.
OCC Should Rescind ‘Heightened Standards’ Guidelines
Washington, D.C. – The OCC should rescind its “heightened standards” guidelines, which focus on process and paperwork over substance and divert bank and examiner attention away from material risks, the Bank Policy Institute and American Association of Bank Directors said in a comment letter filed yesterday.
Research Exchange: February 2026
Regulatory “living will” requirements mandate that large, systemically important banks prepare detailed emergency resolution plans. This study uses an unexpected policy change in May 2018, when banks below a $250 billion asset threshold were suddenly exempted from living will requirements, as the basis for an analysis of how living will requirements affect the behavior of U.S. banks.
BPInsights: February 28, 2026
The U.S. Treasury Department’s Financial Crimes Enforcement Network should reclaim its role in dictating anti-money laundering policy, BPI’s op-ed in American Banker explains. Bottom Line. The key is leadership.
Spoofing, Smishing and Deepfakes: To Stop Scams, Consumers Need Stronger Protections
Americans’ savings are at risk as never before as new, technology-driven fraud and scams are surging across the U.S, costing American households an estimated $12.5 billion in 2024, a 25 percent increase over the previous year. These are just reported losses, with actual totals likely much higher. Using sophisticated technology, scammers are directly targeting unsuspecting consumers, and there’s no better route to a consumer than through their phone and its apps.
BankThink: FinCEN Should Reassert Its Control Over Anti-Money-Laundering Policy
Originally published by American Banker More than five years ago, Congress passed a comprehensive anti-money-laundering and countering the financing of terrorism, or AML/CFT, reform law. The future looked bright, heralding the prospect of an AML regime utilizing innovative technologies to focus on urgent law enforcement and national security priorities.
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